Orchestrate for Insurance
The Failure to Prevent Fraud offence is in force. Your compliance workflow needs to be your defence - not just your policy.
Since 1 September 2025, ECCTA holds large UK insurance organisations criminally liable if they cannot demonstrate reasonable fraud prevention procedures. Orchestrate automates those procedures and builds the evidenced audit trail that constitutes your defence - including four pre-built compliance workflows mapped to the Home Office’s six-pillar reasonable procedures framework.
UK insurance businesses now operate in a compliance environment where manual processes are not just inefficient - they are a liability.
The Failure to Prevent Fraud offence under the Economic Crime and Corporate Transparency Act 2023 came into force on 1 September 2025. Large UK insurance organisations - those meeting two of: 250+ employees, £36m+ turnover, £18m+ in assets - are now criminally liable if an associated person commits fraud for the organisation’s benefit, unless they can demonstrate reasonable fraud prevention procedures. The maximum penalty is an unlimited fine.
Failure to Prevent Fraud demands evidenced procedures, not just policies
The Home Office guidance makes clear that documented, consistently applied and auditable workflows are the strongest evidence of compliance. A policy document that staff may or may not follow is not sufficient. Automated workflows that enforce the same process every time - with every step recorded - are.
High-volume onboarding without consistent AML and sanctions controls
Every new client or policy requires AML screening, identity verification and sanctions checking before cover is bound. When those checks are manual, consistency is impossible to guarantee at scale. A single missed sanctions flag is all it takes to create a material compliance failure.
High-volume onboarding without consistent AML and sanctions controls
Every new client or policy requires AML screening, identity verification and sanctions checking before cover is bound. When those checks are manual, consistency is impossible to guarantee at scale. A single missed sanctions flag is all it takes to create a material compliance failure.
Manual compliance admin grows with every regulatory change
ECCTA, FCA supervisory expectations, sanctions list updates and AML obligations don’t stand still. Without automation, each new requirement adds manual steps to an already stretched compliance function. The only sustainable way to absorb growing regulatory demand without growing headcount is to automate the repeatable.
Orchestrate for Insurance: automated AML, onboarding and Failure to Prevent Fraud procedures - built into one auditable workflow.
Orchestrate replaces the manual, email-driven steps in your onboarding and compliance process with a single automated workflow: running AML checks, sanctions screening, identity verification and compliance sign-off consistently and completely, every time, at any volume.
Every check, every result and every decision is recorded automatically with a timestamp and stored against the client record. That complete, evidenced audit trail is your ‘reasonable procedures’ defence under the Failure to Prevent Fraud offence - built as you work, not assembled after the fact.
That's what workflow automation fixes. Not by adding another app - by digitising the work itself, end-to-end, so it flows.
- Automated AML, fraud and sanctions screening via API
- FCA and ECCTA compliance workflow configuration
- Real-time decision flagging (clear / amber / red)
- GDPR-compliant data handling and role-based access
- API integration with existing policy management and CRM systems
- Failure to Prevent Fraud: four pre-built evidenced procedure workflows
A policy document is not enough. ECCTA requires evidenced procedures.
The Home Office guidance on the Failure to Prevent Fraud offence is clear: “a high-level risk assessment, a policy statement and generic training may not be enough to discharge the reasonable procedures defence.” The onus is on your organisation to prove - on the balance of probabilities - that documented, consistently applied, auditable procedures were in place at the time of any alleged fraud.
For insurance organisations in scope of ECCTA - meeting two of: 250+ employees, £36m+ turnover, £18m+ in assets - Orchestrate’s four compliance workflows directly evidence the six pillars of the Home Office’s reasonable procedures framework. The UK Finance sector guidance confirms that existing FCA compliance frameworks may not automatically satisfy the ECCTA offence: these four workflows close that gap with documented, auditable, automated procedures.
Orchestrate includes four pre-built workflows that map directly onto the six pillars of the Home Office’s reasonable procedures framework:
Fraud Risk Assessment Manager
Structured, documented assessment of fraud risk exposure across the organisation - identifying threats, likelihood, impact and existing controls. Updated on a defined cycle.
Third-Party Fraud Risk Assessment
Systematic due diligence workflow for associated persons - employees, agents, subcontractors and third-party service providers - screening for fraud risk before and during engagement.
Annual Fraud Governance Review
Structured annual review workflow for senior leadership and the board - evidencing top-level commitment, reviewing the effectiveness of fraud prevention procedures, and documenting decisions.
Whistleblowing Form
Secure, confidential reporting workflow for employees and associated persons to report suspected fraud - with automated routing, case tracking and evidenced response.
Each workflow produces a complete, timestamped, auditable record. The Fraud Risk Assessment Manager and Annual Governance Review are configured to your organisation’s specific risk profile. The Third-Party Fraud Risk Assessment runs as part of your standard onboarding and supplier engagement process. The Whistleblowing Form creates a secure, evidenced channel for internal reporting - with automated case routing and a full audit trail.
Taken together, these four workflows constitute the documented, auditable ‘reasonable procedures’ that the ECCTA guidance requires you to evidence - not just assert.
The Third-Party Fraud Risk Assessment workflow is specifically relevant for insurance operations with broker and agent networks. The FCA’s existing requirements for oversight of appointed representatives and agents sit alongside the ECCTA’s due diligence obligations: the Third-Party workflow addresses both simultaneously. The Whistleblowing Form also satisfies FCA SYSC 18 requirements for appropriate whistleblowing procedures.
Relevant legislation & guidance
Be among the first UK insurance operations with a fully automated, Failure to Prevent Fraud-ready compliance workflow.
Orchestrate is already delivering automated compliance and onboarding workflows for UK professional services firms. We are now working with a select group of forward-thinking insurance operations teams - particularly those actively building their Failure to Prevent Fraud procedures and ECCTA compliance frameworks - to implement Orchestrate and establish what best-in-class looks like in this sector.
If your organisation needs to move beyond manual compliance processing and build the evidenced procedures that ECCTA demands - we’d love to talk.
- A compliance workflow configured to your FCA obligations and ECCTA Failure to Prevent Fraud requirements
- All four pre-built FtPF workflows: evidencing all six Home Office reasonable procedures pillars from day one
- Direct access to the Meritec team as your regulatory obligations evolve
Frequently asked questions
What software automates client onboarding for UK insurance companies?
Meritec Orchestrate automates the client onboarding and compliance workflow for UK insurance operations, including AML screening, identity verification, sanctions checking and document collection. It integrates with existing policy management and CRM systems via API and is configured to each firm’s specific compliance requirements. Processing time is typically reduced from days to hours or less.
How does Orchestrate help UK insurance firms comply with the Failure to Prevent Fraud offence?
Orchestrate includes four pre-built compliance workflows that map directly onto the six pillars of the Home Office’s reasonable procedures guidance: Fraud Risk Assessment Manager, Third-Party Fraud Risk Assessment, Annual Fraud Governance Review and Whistleblowing Form. Each produces a complete, timestamped, auditable record that constitutes evidenced reasonable procedures - not just an asserted policy.
What is the Failure to Prevent Fraud offence and does it apply to insurance firms?
The Failure to Prevent Fraud offence under ECCTA has been in force since 1 September 2025. It applies to large organisations: those meeting two of: 250+ employees, £36m+ turnover, £18m+ assets. Qualifying insurance organisations are criminally liable if an associated person commits a specified fraud offence intending to benefit the organisation, unless the organisation had reasonable fraud prevention procedures in place. Maximum penalty: unlimited fine.
Does Orchestrate help insurance firms meet FCA systems and controls requirements?
Yes. Orchestrate’s automated compliance workflows enforce consistent AML screening, sanctions checking and due diligence at every client interaction, creating the documented, auditable systems that FCA supervision expects. The four Failure to Prevent Fraud workflows provide additional evidenced procedures on top of FCA requirements. The platform is ISO 27001:2022 certified, GDPR compliant and hosted entirely in the UK.
Can Orchestrate integrate with our existing policy management system?
Orchestrate is built on Meritec’s own low-code platform with a comprehensive API layer enabling integration with most major policy management, CRM and document management systems. Meritec has 30 years of systems integration experience. Integration scope is confirmed during the initial discovery session before any project commitment.
How long does it take to implement Orchestrate for an insurance operation?
Straightforward onboarding and compliance workflow implementations are typically delivered in six to twelve weeks. The four Failure to Prevent Fraud workflows are pre-built and can be configured to your specific risk profile during the same implementation. Meritec conducts a discovery session before project start with no obligation to proceed.
ISO 27001:2022 certified
Independently audited information security management: the standard regulated firms require from technology partners.
In business since 1996
Independently audited information security management: the standard regulated firms require from technology partners.
UK-based platform and team
Developed, hosted and supported entirely in the UK. Your client data does not leave UK jurisdiction.
Proprietary platform — no third-party dependency
Meritec owns its platform IP. Your workflows aren’t subject to a third-party vendor’s roadmap changes or pricing decisions.
It’s time to make your work flow.
Tell us how your team currently handles onboarding, compliance and Failure to Prevent Fraud obligations. We’ll show you how Orchestrate automates your ECCTA procedures and builds the evidenced audit trail that constitutes your reasonable procedures defence.
